News & Analysis as of

Diverted Profits Tax - What Arrangements May Be Caught?

BACKGROUND AND INTRODUCTION - The UK Government has announced the introduction of the Diverted Profits Tax (or 'DPT') - a new tax which will have effect from 1 April 2015. The tax is intended to target two types of...more

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google's chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK,...more

Diverted Profits Tax and You: What does it mean?

A New Tax on doing business in or through the UK - The UK is on course to enact a new tax (the "DPT") with extraterritorial scope which will apply to profits arising on or after 1 April 2015 and will be applied at a...more

Distressed Debt - UK Tax Changes

We discuss below changes to UK tax law in respect of corporate debt which take effect from the beginning of this year which will improve the UK tax position for distressed debt of a UK company....more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

The UK’s New Diverted Profits Tax

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

"UK Government Announces New 25 Percent Diverted Profits Tax"

On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

Autumn Statement 2014

On December 3, 2014, George Osborne delivered his Autumn Statement. Traditionally, the purpose of this has been to update economic projections and department spending allocation, but increasingly it includes statements...more

UK: Autumn Statement- More good news for the creative sector

On 3 December 2014, as part of his Autumn Statement, the UK Chancellor announced the introduction of a new children’s TV tax relief which is due to be introduced from April 2015....more

UK Autumn Statement 2014

Today’s Autumn Statement saw financial institutions hit by a surprise proposal to limit the proportion of their profits which can be reduced by the carry forward of past losses, which will mean tax is paid on those profits...more

Autumn Statement 2014: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Shortly after 12.30 p.m. today, the U.K. Chancellor of the Exchequer, George Osborne, delivered the last Autumn Statement before next year’s general election....more

No UK corporation tax deduction for penalty imposed under the code of the Fédération Internationale de l'Automobile ("FIA")

In an appeal by HMRC against a decision of the First-tier Tribunal ("FTT"), the Upper Tribunal (Tax and Chancery Chamber) ("UT") decided that a penalty imposed on McLaren Racing Limited ("McLaren") in respect of a breach of...more

Time For a New Home?

The high number of companies, mostly U.S., eyeing acquisitions or ventures that will allow them to redomicile their business in the UK and Ireland is a major theme of this report. Mostly, it is about tax. But there is quite a...more

As Congress Seeks Additional Funding, Inversion Proposal Emerges

Throughout the past several weeks, Pfizer’s attempt to acquire AstraZeneca has garnered significant congressional and media attention. Pfizer, a U.S. multinational corporation, made a bid for AstraZeneca in an effort to move...more

UK's Upper Tribunal decision in Greene King: tax and accounting

SPEED READ - The Upper Tribunal has upheld the Firsttier Tribunal’s (FTT’s) decision in Greene King. Planning designed to obtain a deduction with no taxable receipt was held to have failed. While the law has changed...more

Corporate Inversions–Fencing In U.S. Businesses

The U.S. has a tax competitiveness problem – its effective corporate tax rates are among the highest in the world. Once upon a time the U.S. was on the low end, and attracted business and capital. Now that it is on the high...more

Bakorp: Appeal Dismissed For Failure To Comply With Large Corporations Rules

In Bakorp Management Ltd. v. The Queen (2014 FCA 104), the Federal Court of Appeal upheld a decision of the Tax Court dismissing the taxpayer’s appeal for failure to comply with the rules relating to objections and appeals...more

UK Employment Law and Share Incentive Developments - Spring 2014

Changes to LLP member taxation and employee incentive schemes could have wide ranging implications for UK employers. Background – As always 6 April means a new UK tax year and a raft of employment and...more

UK Budget 2014: corporate, finance and real estate tax highlights

We set out below a summary of key items of interest announced by the UK’s Chancellor in the Budget on 19 March 2014 relating to businesses, corporate and finance taxation and real estate taxation. Much of what was announced...more

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

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